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ARTICLE · 23 JUNE 2026

New CRA Commentary Provides Practical Clarity On The Voluntary Disclosures Program (VDP)

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Under the previous policy, relatively low threshold CRA contact (such as a request for information or a broad educational letter) could be sufficient to disqualify a disclosure. The updated policy instead focuses on whether the CRA has initiated an audit or investigation - that is, whether significant compliance work on the specific issue has already begun.

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Lori Bokenfohr
Lori Bokenfohr
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The Canada Revenue Agency (CRA) recently provided administrative guidance on the operation of the Voluntary Disclosures Program (VDP) in a national webcast with the Society of Trust and Estate Practitioners (STEP) Canada on June 18, 2026, followed by a Q&A session. The CRA’s comments clarify how it is applying the revised VDP policy under Information Circular IC00-1R7 (effective October 1, 2025), particularly in assessing whether a disclosure remains voluntary and whether it is characterized as prompted or unprompted.

These distinctions are central to determining whether access to the VDP remains available and the level of relief that may be obtained.

When is a Disclosure “Voluntary”?

Under the previous policy, relatively low threshold CRA contact (such as a request for information or a broad educational letter) could be sufficient to disqualify a disclosure. The updated policy instead focuses on whether the CRA has initiated an audit or investigation - that is, whether significant

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